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PRIVACY POLICY

May 2024




PRIVACY POLICY

Everflow Technologies Inc. (“Everflow”, “we”, “us”, “our”) provides web-based
advertising network, affiliate tracking, targeting, reporting and analytics
services (“Platform Services”), that are facilitated by Everflow’s cloud
platform (“Platform”), to our customers (“Everflow Customers”). Everflow also
operates its corporate website www.everflow.io (“Website”). This Privacy Policy
explains how Everflow processes (i) data from Everflow Customers’ end users
(“End Users”) on behalf of Everflow Customers; and (2) Website Visitor
Information (as defined herein).

Everflow is a “data processor” or “service provider” that collects and processes
End User data at the instruction of Everflow Customers (“data controllers”).
Everflow Customers determine the data that they provide to and collect through
Everflow; their use, collection, exportation, or any other use of End User data
is subject to their respective privacy policies and applicable laws, and
regulations.

Throughout this Privacy Policy, when we use the words “you”, “your”, or “user”,
we mean an individual End User of an Everflow Customer viewing ads displayed
using the Platform Services. Everflow Website visitors are referred to as
“Visitors”.

Everflow Customers and End Users

This Privacy Policy does not address the practices or policies of Everflow
Customers, nor of any website, mobile app, or other property on which ads are
displayed using the Platform Services. Everflow is solely a technology and tools
provider and does not engage in brokering, displaying or executing any ad
campaign. Everflow Customers use the Platform Services and collect and process
End User personal information and data, including Collected Information (as
defined herein), for the purpose of marketing to individuals (“Personal Data”).
For clarification, Personal Data includes Collected Information and Visitor
Information (as defined herein).

Everflow Customers own the Personal Data that they provide to and collect
through the Platform Services. The collection, retention, processing and other
uses of data by Everflow Customers, whether or not in connection with the
Platform Services, is governed by their own privacy policies and applicable
laws, rules, or regulations. Everflow does not control those Everflow Customer
activities.

Collected Information

At the instruction of Everflow Customers, Everflow collects the following types
of information from End Users (“Collected Information”):

 * Cookies
 * IP addresses
 * Browser user agent
 * Ad Identifiers (unique character strings associated with user devices that
   help monitor and measure user interactions with advertisements and apps, such
   as Apple’s IDFA and Google Ad ID; Ad Identifiers may be reset by the user)
 * Approximate geographic location data derived from IP address and/or wifi
   networks
 * Pixel tags

Everflow Customers may also share account information for their End Users and
their Platform partners on the Platform, including company and employee
information necessary to maintain the Platform Services and contact information,
including: name, mailing and/or billing address, email address, company name,
website url, user name, password, and phone number. Everflow Customers that
manage payouts to their Platform partners may share related banking information.

Everflow Customers can also manage information provided by other third-party
sources in the Platform, including advertisers, publishers, marketing partners,
and other advertising networks and analytics partners. Marketing partners may
sign up with advertisers through the Platform.

Data Protection Laws

Each Everflow Customer is the data controller with respect to Personal Data.
Under the applicable laws of various countries, you may have certain rights
concerning your Personal Data, such as under EU law, the right to access to,
rectification or erasure of, and/or restriction of processing or objection to
processing of your Personal Data. If you believe that an Everflow Customer has
collected or processed your Personal Data, and you have any questions or want to
exercise any of your rights with respect to your Personal Data, you should
contact them directly.  

If you are a resident in the European Union, you also have the right to a
complaint with EU data protection authorities, at no cost. This right may also
exist in other countries. If you have questions please ask the relevant Everflow
Customer or the data protection authority in your country.

Everflow operates as a “data processor” under the General Data Protection
Regulation (“GDPR”) and as a “service provider” under the California Consumer
Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020
("CPRA"). Everflow adheres to these data protection laws. Accordingly, we
generally do not have the authority to provide access to or deletion of your
Personal Data; you will have to contact the relevant Everflow Customer.

Collection, Use and Disclosure of Personal Data Collected via the Website


Everflow does not sell Personal Data it collects from Visitors through the
Website. Personal Data we do collect through the Website, the business purpose
for which we collect it, and the service providers or other third parties who
may receive it are in the table below:

‍



Collection, Use and Disclosure of Personal Data Collected via the Platform
Services


Everflow does not sell Personal Data it collects via the Platform Services.
Personal Data we do collect through the Platform Services, the business purpose
for which we collect it, and the service providers or other third parties who
may receive it are in the table below:

‍





We do not knowingly collect or sell the Personal Data of minors under the age of
16.

Please see our General Data Protection Regulation (GDPR) policy for additional
information. For questions or requests, see our contact information below.

California Resident Rights

If you are a California resident, you have the rights outlined in this section.
If there are any conflicts between this section and any other provision of this
Privacy Policy and you are a California resident, the portion that is more
protective of Personal Data shall control to the extent of such conflict.

To the extent applicable and provided for by law, California residents have the
following privacy rights in relation to the Personal Data we collect:

 * The right to know: End Users and Visitors have the right to know what
   personal information we have collected and how we have used and disclosed
   that Personal Data;
 * The right to delete: End Users and Visitors have the right to request
   deletion of their Personal Data;
 * The right to non-discrimination: End Users and Visitors have the right be
   free from discrimination relating to the exercise of any of their privacy
   rights.

Exercising Your Rights: California residents can exercise the above privacy
rights or request to receive this notice in a different format by emailing us
at: privacy@everflow.io.

Verification: in order to protect Personal Data from unauthorized access or
deletion, we may require End Users and Visitors to verify their identification
before they can submit a request to know or delete Personal Data. If we suspect
fraudulent or malicious activity, we may ask for additional Personal Data for
verification. If we cannot verify their identity, we will not provide or delete
their Personal Data.

Authorized Agents: End Users and Visitors have the right to designate an
authorized agent to make requests to us to exercise any rights under the CCPA or
CPRA.  


How Do Everflow Customers Collect End User Information Using Everflow Platform
Services?

The Everflow Platform Services allow Everflow Customers to collect various kinds
of information about their End Users (“Collected Information”).

Everflow Customers can use the Platform Services to create “cookies” (small text
files that are saved by your browser) and “pixel tags” or “web beacons”
(one-pixel graphic files which are delivered from the Platform Services web
server) that can be placed in advertisements or on websites or other apps to
collect information about user interaction with the advertisements or websites.
Everflow also supports server-to-server measurement for some Everflow Customers.
With any of the mentioned methods, when an End User views or clicks on an
advertisement, goes to a specific web page, or takes any other action that an
Everflow Customer chooses to monitor, the Everflow Platform Services collect
information from the End User’s computer or device, as described below.

Log Data. The Platform Services automatically record certain information (“Log
Data”) when an advertisement is displayed to an End User through the Platform
Services, or when an End User views a web page with a cookie or pixel tag
created with the Platform Services. Log Data may include information such as an
End User’s Internet Protocol (IP) address and network status, mobile device
identifier, application identifier, browser type, operating system, the pages or
page features which an End User browsed and the time spent on those pages or
features, frequency with which the Platform Services encounter the same End
User, search terms, the links or advertisements on which an End User clicked,
and other statistics.

Advertising Identifiers. As part of the Log Data, the Platform Services may
collect advertising identifiers, which are resettable identifiers unique to your
mobile device, and which are used in connection with advertising delivered to
your mobile device. Examples of advertising identifiers include IDFA (developed
by Apple for the iPhone) and Google Ad ID (developed by Google for Android). If
you don’t want advertising identifiers to be used to provide targeted
advertising to you, see the section below titled “Opting Out of Targeted
Advertising”

Location Information. The Platform Services may collect and store information
about where you are located, both by collecting precise geolocation information
from your mobile device if and as permitted by you, and by converting your IP
address into a rough geolocation and utilizing your mobile phone number to
approximate rough geolocation information (based on area code).

How Do Everflow Customers Use Everflow to Process Information from their End
Users?

Everflow Customers use information according to their own privacy policies and
applicable laws and regulations. However, Everflow provides the following types
of data analysis functionality within the Everflow Platform Services for use by
Everflow Customers and only as directed by Everflow Customers:

 * Measuring the performance of advertising campaigns (including fraudulent
   activity);
 * Identifying possible relationships among different browsers and devices;
 * Limiting the number of times a specific advertisement is presented to the
   same browser or mobile device (frequency capping);
 * Creating customized performance reports (for example, how well a particular
   advertisement is performing in a particular geographic region or among a
   particular demographic); and
 * Improving the targeting or relevance of advertising to users.

How Does Everflow Use Everflow Customers’ Collected Information?

We use the information collected through the Platform Services to provide,
improve, and promote the Platform Services; uses include the following:

 * To provide the Platform Services to and for the Everflow Customer on behalf
   of which the Platform Services collected the information, as described in
   this Privacy Policy; and
 * To monitor, research, analyze and report on the usage of the Platform
   Services, solely on an aggregate, non-identifiable basis.

How Long Does Everflow Retain Personal Data

Each Everflow Customer sets the Personal Data retention period. If you have
questions or want more details, please contact the relevant Everflow Customer.
Everflow retains Personal Data that it processes on behalf of each Everflow
Customer for as long as needed to provide Platform Services as directed by that
Everflow Customer. Everflow will also retain Personal Data as necessary or legal
purposes (for example, to comply with its legal obligations, resolve disputes,
and enforce its agreements).

What Information Does Everflow Share With Third Parties?

Service Providers. We may engage third party service providers to work with us
to administer and provide the Platform Services. These third party service
providers have access to Personal Data only for the purpose of performing
services on our behalf.

Third Parties. We may share aggregated, non-identifying information with third
parties for industry analysis, demographic profiling and other similar purposes.

In Connection with Business Transactions. Personal Data is considered to be a
business asset. As a result, if we go out of business or enter bankruptcy or if
we are acquired as a result of a transaction such as a merger, acquisition or
asset sale, Personal Data may be disclosed or transferred to the third-party
acquirer in connection with the transaction.

For Our Protection and the Protection of Others. It is our policy to protect you
and Visitors from privacy violations from  abuse of the legal systems, whether
by individuals, entities or government, and to contest claims that we believe to
be invalid under applicable law. However, it is also our policy to cooperate
with government and law enforcement officials and private parties. Accordingly,
we reserve the right to disclose any information about you or Visitors to
government or law enforcement officials or private parties in order to: (a)
satisfy or comply with any applicable law, regulation or legal process or to
respond to lawful requests, including subpoenas, warrants or court orders; (b)
enforce our agreements with you or third parties, to protect our property,
rights and safety and the rights, property and safety of third parties or the
public in general; and (c) prevent or stop activity we consider to be illegal or
unethical.

Opting Out of Targeted Advertising

Everflow Customers may use the Platform Services to provide ads that are likely
to be interesting and relevant to End Users (“Targeted Advertising”). One way
Everflow Customers may do this is by gathering Collected Information related to
End Users, which may include elements like mobile websites you have visited or
mobile apps that you use, preferences that you may have provided to your app
provider or to the Everflow Customer, information collected by third parties or
Everflow and shared with the Everflow Customers, advertising identifiers, or
location information (e.g., GPS or Wi-Fi data if you have enabled those
services). Everflow Customers may also link an identifier to additional
information from other partners to provide the Everflow Customer with
information about users’ likely interests.

If you or a Visitor wishes to "opt out" of Targeted Advertising based on the
types of techniques described above, your options include the following:

 * Visit www.networkadvertising.org/choices or www.aboutads.info/choices/.
 * Reset your mobile device’s advertising identifier or set it to opt out of
   targeted advertising.
 * Android: You can reset your advertising ID at any time, right from the Ads
   section of the Google Settings app on your device. From the same app, you can
   also opt-out of targeted advertising based on the advertising ID by setting
   the appropriate ad tracking preference.
 * iOS: You can opt out of targeted advertising by accessing the following link
   on your device: http://oo.apple.com. Alternatively, if you are using the iOS
   6 or above operating system on your device, you may opt-out by electing Limit
   Ad Tracking in your device’s settings menu (as of the date of this Privacy
   Policy, located at Settings > Privacy > Advertising).

You should be aware that if you or a Visitor “opts out” it does not mean that
you or Visitor will no longer receive advertising. It just means that the
advertising you or Visitor sees displayed will not be customized and may be less
relevant.

What Information Does Everflow Collect Directly From Everflow Customers?

Everflow requires personnel contact details to set up an Everflow Customer
account – including mailing and/or billing address, email address, company name,
and website URL. Everflow Customers also need to provide a username and
password. All of this information is handled according to the service agreement
between Everflow and the Everflow Customer.

Information Security

We take commercially reasonable measures to protect Personal Data from
unauthorized access, use or disclosure. Please be aware, however, that no method
of transmitting information over the Internet or storing information is
completely secure. Accordingly, we cannot guarantee the absolute security of any
information.

International Transfer

Your Personal Data (including personally identifiable information) may be
transferred to, and maintained on, computers located outside of your state,
province, country or other governmental jurisdiction where the privacy laws may
not be as protective as those in your jurisdiction. See our Data Processing
Addendum for international data transfer information. Currently, we use servers
located in data centers within the United States.

Our Policy Toward Children

We instruct Everflow Customers not to use the Platform Services to direct
advertising to children under 13 (16 in the EU) and we do not knowingly collect
personally identifiable information from children under 13 (16 in the EU). If we
learn that we have collected personally identifiable information of a child
under 13 (16 in the EU) we will take steps to delete such information from our
files as soon as possible.

What Visitor Information Does Everflow Collect on the Everflow Website

When a Visitor visits the Website, Everflow collects information about his/her
device and use of the Website to improve the Website (“Visitor Information”).
Everflow also collects any Visitor Information a Visitor voluntarily provides
when he/she visits the Website. The type of Visitor Information Everflow
collects from a Visitor will depend on his/her request or interaction with the
Website. Types of Visitor Information Everflow collects from a Visitor may
include specific times of day he/she accesses the Website, the IP address of the
device a Visitor used to access the Website, the pages on the Website that a
Visitor viewed, the pages a Visitor visited before navigating to the Website,
and information about the device a Visitor uses to access the Website, including
hardware model, operating system and version, and browser.

Everflow uses Visitor Information collected on the Website for various purposes,
including:

 * Ensuring its Website remains relevant to end user needs and are easy to use
   by providing analytics and other data regarding use of our Website
 * Sending marketing and promotional communications in compliance with
   applicable laws
 * Enhancing, improving, or modifying its Website and services, enhancing
   security, or combating spam or malware or other security risks
 * Providing confirmations, invoices, technical notices, updates, security
   alerts, and other support and administrative messages
 * Providing Targeted Advertising

Everflow uses cookies to store Visitors’ individual user preferences in order to
make their user experience more enjoyable in the future. A cookie is a piece of
information stored by device browsers used to access the Website. Most browsers
are initially set up to accept cookies by default. A cookie is generated by a
web page server, which is basically the computer that operates a web site. The
information the cookie contains is set by the server and it can be used by that
server whenever the user visits the site.

There is a simple procedure in most Internet browsers to disable cookies. More
information about how to reject cookies using internet browser settings can be
found in the “Help” section of Internet browsers; alternatively visit
https://www.cookiesandyou.com/. However, note that cookies may be required to
use certain features of the Website, as well as other sites in general.  

The Website may include links to other websites (“Third Party Websites”) with
their own governing privacy practices and policies. We encourage Visitors to
carefully read the privacy policy of any Third Party Websites they visit.

Changes to Privacy Policy

Everflow may change this Privacy Policy from time to time (“Revision”). We may
inform you of any such changes by posting the revised version to our website at
the same URL as the original version, or by sending notice via email
(collectively, “Revision Notice”).

Contact Information

Please contact us at privacy@everflow.io if you have any requests or questions
about our Privacy Policy.‍

Data Protection Officer
Everflow’s designated Data Protection officer is Emma Rogers who may be
contacted at dpo@everflow.io.

‍

‍

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